Fish Overboard: Did the UK Throw Away 7,500 tonnes of North Sea Cod?

A freedom of information request to the UK’s fisheries management body (the Marine Management Organisation) has revealed that despite the landing obligation having applied to all catches of North Sea Cod from January 2018, zero tonnes of unwanted undersize cod were landed by the UK fleet from 1 January - 15 November, in comparison to at least 7,500 tonnes accounted for in the quota setting.

The landing obligation required all UK fishers to count and land unwanted undersize North Sea cod since January 2018, but data provided to Our Fish by Marine Management Organisation (MMO) suggests that while an enormous 5,200 tonnes of extra quota was given to fishers to cope with the burden of landing extra fish, it appears to have been used to land even more adult fish, mostly in Scotland and England.

“Of an estimated 5,200 tonnes of expected undersize cod, absolutely zero had been landed by November 2018. The UK instead landed a total catch of 21,596 tonnes of adult cod.

This suggests that, extrapolating the percentage of undersize fish, at least 7,500 tonnes of undersize fish were illegally discarded, and the UK’s total catch of North Sea cod could actually have been over 29,000 tonnes, or around one third above the quota”, said Rebecca Hubbard, Program Director for Our Fish.

“This unreported catch would represent an enormous waste of valuable fish, and significantly worsen overfishing of the iconic north sea cod stock. This is extremely concerning; in recent years north sea cod was thought to be recovering, however the outlook is again looking very poor with scientists recommending a huge cut for 2019 fishing limits.”

The International Council for the Exploration of the Sea (ICES) advised that for cod in the North Sea, Skagerrak and the English Channel, total catches should be no more than 53,058 tonnes in 2018. This included an estimated 17,333 tonnes of unwanted bycatch - equivalent to 32% of all cod landings in those areas. The discard ban requires that this 17,333 tonnes is landed and counted against quota to inform science, and to incentivise not catching it in the first place.

The EU Council approved a total catch limit of 43,156 tonnes for 2018 for the North Sea - including a “top-up” of 13,414 tonnes, which was designed to allow the unwanted catch to be landed without it using up all fishing vessel’s existing quota [5]. Of this total for the North Sea, the UK was allocated 16,808 tonnes, including a “top-up” of 5,224 tonnes to account for fish that would have to be landed because of the discard ban.

According to data released under a freedom of information request by the MMO to Our Fish, the UK fleet recorded landings of 21,596 tonnes of cod up until 15th November 2018, but none of those landed were unwanted sizes i.e. all of the fish landed was wanted and saleable.

Assuming the UK landed it’s entire North Sea and Skaggerak Cod quota of 16,808 tonnes, extrapolating the “top-up” would equate to at least 7,500 tonnes of undersize cod - adding up to a total of some 29,000 tonnes caught.

“The UK government appears to be aware that large-scale unreported, illegal fishing for an important stock like cod is taking place within its fishing fleet, yet the Marine Management Organisation (MMO) and Marine Scotland seem to be turning a blind eye. It is incomprehensible and indefensible that such rampant non-compliance would be simply ignored”, she continued. “The UK fishing industry reportedly supports remote electronic monitoring as a requirement for EU vessels accessing UK waters after Brexit, however it is clear from this data, that the UK needs to start implementing this technology with its own fleet first.”

“Our Fish has written to the European Commission, requesting that they take at least 7,500 tonnes off the UK 2019 North Sea Cod quota to account for the unreported undersize cod from 2018 [9]. We are also urging the UK to hold aside quota for discards in the 2019 cod quota, and only release it if discards are landed in ports, and all catches are documented through remote electronic monitoring or onboard observers in medium-very high risk discarding fleets,” said Ms Hubbard.

The iconic North Sea cod stock, considered a favourite for UK consumers, was heavily overfished for most of the 80s and 90s, but due to strong intervention, had started to show signs of recovery in the last ten years. However, forecasts of the state of the stock again worsened in 2018, and ICES proposed a radical cut to the TAC of almost 50% from 2018 levels. [10]. Despite a commitment to end overfishing, the annual fishing limit (TAC) for North Sea Cod in 2019 was set 25% above scientifically advised levels by the EU Agrifish Council.

The lack of landings of unwanted catches in the UK has also been confirmed by other members of the fish processing industry, who were expecting to receive the unwanted catches to process into other fish byproducts (the Landing Obligation requires that unwanted and undersize catches are only used in industries outside of direct human consumption markets, such as fishmeal, fish oil, pet food, food additives, pharmaceuticals and cosmetics).

Pelagia General Manager Mike Hryckowian, in correspondence with Our Fish, sais there has been a tiny volume sold into the fishmeal sector in Aberdeen (serviced by Fraserburgh and Peterhead) and zero volume into Grimsby (serviced by all English ports)

He said, "I am absolutely certain that if discards were to be landed our factory would receive some if not all of them, because we are one of the few, if not the only, establishment in England capable of dealing with every type of fish discard and in any volume."

The low uptake of product into fishmeal production in both Aberdeen and Grimsby fishmeal plants consolidates the landings data provided by the Marine Management Organisation.

The issue of non-compliance with the landing obligation does not only apply to the UK fishing fleet. The European Commission has proposed the introduction of remote electronic monitoring systems, including CCTV, into the EU fleet in order to properly monitor and enforce the landing obligation, through the revision of the Control Regulation.

Martin Banks is a highly qualified journalist with many years experience of working within the EU institutions. He is an occasional, and highly valued, contributor to EU today, writing on a wide variety of issues.